Com 8295p

17th September 2015 NO. 95, Jalan Masai Utama 1, Taman Masai Utama, 81750 Masai, Johor Dear TMG Pyramid Sdn Bhd Supplier,

COM GROUP CODE OF BUSINESS CONDUCT You are receiving this letter as your company has been invited to tender for supply to Com Group Asia & Pacific As part of Com Group’s corporate responsibility, we would like to remind you of your obligations under our Code of Business Conduct (Com CBC), and detail is enclosed to this letter. As a supplier of Com, you must carefully review the Com CBC, ensure that the Com CBC is disclosed to all your personnel; and undertake and agree that, in connection with your performance under your agreement with Com, all of your personnel shall act consistently with the principles of the Com CBC. Please read the documents, and then acknowledge your receipt by g this letter below, including a job title and date. Return to Com Group Supply Chain with your RFP submission. We thank you for adherence to our Code of Business Conduct and Code of Ethics, and for your request for proposal submission. I hereby agree that I have read, understand and will adhere to the Com Group Code of Business principles. SIGNED for and on behalf of TMG Pyramid Sdn Bhd by its duly authorised representatives:

Signature

FAZIRA DIANA SALES COORDINATOR Date:

17th September

2015

Com Group Malaysia Sdn Bhd Suite 25.03, Level 25, Johor Bahru City Square Office Tower, 106-108, Jalan Wong Ah Fook, 80000 Johor Bahru, Johor

Details regarding Com Group Code of Business Conduct

1. Supplier shall comply with the Com Group Code of Business Conduct, AntiCorruption Undertakings and the Code of Ethics, as set out below. Any noncompliance to the provisions may lead to immediate termination of this Agreement. (A) Com has a Code of Business Conduct (the “Com CBC”). An electronic

copy can be ed from the following web site: http://www.com-group.com/1124.htm Supplier shall: o

Carefully review the Com CBC;

o

Ensure that the Com CBC is disclosed to all Supplier’s personnel; and

o

Undertake and agree that, in connection with Supplier performance under this Contract, all Supplier personnel shall act consistently with the applicable principles of the Com CBC in all material respects.

(B) Anti-corruption undertakings As a matter of corporate policy and as strictly prohibited under the Com CBC, Com expressly prohibits payments or offers of bribes and/or facilitation payments (otherwise known as “grease” payments) in connection with Com business operations by any supplier or agent engaged to provide goods or services to Com. 1. Supplier undertakes and agrees that in connection with this Contract and the transactions contemplated by this Contract, it will comply with all applicable laws, rules, regulations, decrees and/or official governmental orders of the United Kingdom, the United States of America and the country of operations relating to anti-corruption and anti-money laundering. 2. Supplier agrees, undertakes and confirms that it and each member of the Supplier Group, has not made, offered, promised to make, authorized the making of, and will not make, offer, or promise to make, or authorize the making of, any payment or other transfer of any financial or other advantage or anything else of value, including without limitation the provision of any funds, services, gifts or entertainment, directly or indirectly to any: (a) (b)

government official; director, officer, employee or agent/representative of an actual or prospective counterparty, supplier or customer of Com;

Com Group Malaysia Sdn Bhd Suite 25.03, Level 25, Johor Bahru City Square Office Tower, 106-108, Jalan Wong Ah Fook, 80000 Johor Bahru, Johor

(c)

director, officer, employee or agent of Com or its co-ventures or any of its or their s;

(d)

political party, official of a political party, or candidate for public office;

(e)

agent or intermediary for payment to any of the foregoing; or

(f)

other person or entity;

for the purpose of obtaining, rewarding or influencing the award of this Contract or for any improper advantage or improper purpose or where it would be improper for the person to accept such an advantage in connection with the performance of this Contract and the transactions contemplated hereunder or in connection with any other business transactions involving Com, if and to the extent that to do so is or would be in violation of or inconsistent with the principles or requirements of any anti-bribery or antimoney laundering laws applicable to Com or to Supplier, or to their respective parent companies, including, but not limited to, the UK Bribery Act 2010, the UK Anti-Terrorism, Crime and Security Act 2001, the U.S. Foreign Corrupt Practices Act and successor legislation, legislation implementing the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions or the United Nations Convention Against Corruption, and/or the anti-corruption or anti-money laundering laws of the country of operations. (C) Compliance with Ethics: Supplier will not in any way, offer directly or indirectly, any illegal payments, remuneration, gifts or comparable benefits to any employee which are intended or perceived to obtain business or uncompetitive favors for the conduct of its business excepting nominal gifts which are customarily given and are of commemorative nature for special events.

Com Group Malaysia Sdn Bhd Suite 25.03, Level 25, Johor Bahru City Square Office Tower, 106-108, Jalan Wong Ah Fook, 80000 Johor Bahru, Johor